September 21, 2022
INTRODUCTION 2023 will be a year of substantive climate change action as all EU market participants (EMPs) and China market participants (CMPs or together Financial MPs) will be accountable to comply1 with a plethora of rigorous and exacting disclosure requirements on how they are managing emissions. Given that China has been the largest CO2 contributor for the last decade2 and consistently responsible for nearly a third of the world’s emissions3 since 2018, it is in the best position to improve the global trajectory. The table below shows the top carbon emitters by jurisdiction. Accurate emissions measurement matters, given that significant change is required to adjust the current direction (shown below) and avoid impending issues caused by global temperature rise. This article describes the complexity of emissions measurement among multinational corporates in China and their related investment community, given the dynamic multi-jurisdictional regulatory landscape. It then demonstrates the current issues and concludes with a practical means to navigate them. GLOBAL REGULATORY MOVEMENT As mentioned, China and the EU have established significant systems (i.e., regulations and carbon measurement via their Emission Trading Systems (ETS)) that require immediate action from FMPs to meet 2023 mandatory reporting requirements. 2023 compliance deadlines should be feasible, given the impetus began in 2015 via COP214, where leaders5 pledged to have strategies implemented within five years. However, most regulatory announcements occurred around the five-year mark (2020) and have accelerated since. Most critical are the major emitters.6 Among them, the EU and China7 have made the greatest regulatory strides. Accordingly, FMPs in these markets are facing an imminent and arduous compliance feat. For example, in March 2020, the...